Section 681DK | Manner of apportionment

(1)Subsections (2) and (3) apply if—

(a)a payment or sum is to be apportioned under section 681DJ or under section 880 of CTA 2010,

(b)at the time of the apportionment it appears that it is material to the liability to tax (whether income tax or corporation tax, and for whatever period) of two or more persons (in this section referred to collectively as “the set”),

(c)a question arises as to the manner in which the payment or sum is to be apportioned, and

(d)at the time of the apportionment, it appears that the apportionment is material to the income tax liability (for whatever period) of—

(i)a person, or some two or more persons, in the set, or

(ii)all the persons in the set.

(2)For the purposes of income tax of the person or persons mentioned in subsection (1)(d), the question is to be determined in the same way as an appeal.

(3)All the persons in the set are entitled to be a party to the proceedings.